Louth County Council Draft Development Plan 2021 2027 - ESB Group Property Submission on behalf of ESB to the Louth Draft County Development ...
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ESB Group Property Louth County Council Draft Development Plan 2021 - 2027 Submission on behalf of ESB to the Louth Draft County Development Plan 2021–2027. 23/12/2020
Contents
1. INTRODUCTION ......................................................................................................................... 3
Overview of ESB Strategy .................................................................................................... 3
Generation, Transmission & Distribution ............................................................................... 3
ESB Roll-out of EV Infrastructure & Hydrogen Projects ........................................................ 4
ESB Telecoms & Telecommunications Infrastructure ........................................................... 4
2. PLANNING POLICY & THE DRAFT CDP .................................................................................... 4
Electricity Transmission & Distribution .................................................................................. 5
Generation & Renewables .................................................................................................... 6
Onshore Wind Energy ................................................................................................... 7
Offshore Wind & Marine Renewables ............................................................................ 8
Solar .............................................................................................................................. 8
Energy Storage.............................................................................................................. 9
Hybrid Renewables ..................................................................................................... 10
Demand Management ................................................................................................. 10
Telecommunications ........................................................................................................... 10
Sustainable Transport & Electric Vehicles .......................................................................... 11
Other Sustainable Transport ........................................................................................ 12
3. CONCLUSION........................................................................................................................... 12
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 21. INTRODUCTION
Electricity Supply Board (ESB) welcomes this opportunity to make a submission to the Louth Draft County
Development Plan (CDP) 2021 – 2027. ESB is a landowner and employer in Louth with property and
infrastructural assets throughout the County. As a strong, diversified, vertically integrated utility, ESB
operates right across the electricity market; from generation, through transmission and distribution to
supply of customers. In addition, ESB uses its networks to carry fibre for telecommunications and to
provide charging infrastructure for electric vehicles. ESB is Ireland's leading electricity utility with
approximately 3.2 million customers throughout the island of Ireland.
ESB broadly supports the vison included in Draft CDP. We recognise that Louth Co. Co. has a strong
reputation in placing climate action at the heart of all policies and strategies. However, there continues
to be significant advancement in renewables technology and outlined below are observations regarding
strategic issues that should be taken into consideration in the preparation of the final Louth CDP 2021 -
2027.
Overview of ESB Strategy
ESB is Ireland’s foremost energy company and the largest supplier of renewable electricity in Ireland.
Through innovation, expertise and investment, ESB is leading the way in developing a modern,
efficient electricity system that is capable of delivering sustainable and competitive energy supplies
to customers in the ‘all-islands market’ (Republic of Ireland, Northern Ireland, England, Wales and
Scotland). ESB operates a renewable energy portfolio that has the capacity to supply over 830 MW
of green energy to the homes, farms, hospitals, schools and businesses of Ireland and the United
Kingdom.
ESB is embracing new technologies that are revolutionising the energy industry, including smarter
electricity networks. We are investing in sustainable energy solutions that harnesses the power of
solar, wind, wave and storage to provide a cleaner future. Our goal is to reduce ESB’s carbon
emissions 40% by 2030 and move towards becoming carbon-neutral by 2050. By the end of 2020,
ESB will be delivering one-third of its electricity from renewable generation as it progresses towards
achieving carbon net-zero operations which is consistent with the objectives of the National Planning
Framework (NPF) and Regional Spatial & Economic Strategy (RSES) for the Eastern & Midland
Region.
Generation, Transmission & Distribution
ESB has partnered with Parkwind to develop two offshore wind farms in the Irish Sea, at Oriel and
Clogherhead off the coast of County Louth. The Oriel project (330MW) is currently at an advanced
stage of design, while investigations are just commencing at Clogherhead. The project team for the
Oriel Windfarm have recently completed updated geo-technical and environmental surveys and
expect to apply for consent to the relevant planning authorities in 2021. Once operational, the Oriel
Windfarm will generate enough capacity to cover the needs of approximately 280,000 households –
most of the population in counties Louth and Meath.
ESB is the asset owner of the Transmission System and Distribution System and ESB Networks
provides the essential service of building, managing and maintaining the electricity networks in Louth
and throughout Ireland. ESB Networks is unique in that it is in direct contact with all electricity users.
The electricity network extends to over 180,000km across the Republic of Ireland and in 2018 over
26,900 new residential and business connections were completed. The focus of recent investment
in the network was on continuing the reinforcement of the system to facilitate the connection of new
renewable electricity generation.
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 3ESB Roll-out of EV Infrastructure & Hydrogen Projects
ESB, has developed a network of almost 1,100 electric vehicle charge points across the Island of
Ireland. In the Climate Action Plan (2019) the Irish Government has set stretching targets for EV
adoption in Ireland in order to address energy demand and emissions from transport. To help meet
this increase in electric vehicles, ESB, with the support of the Government’s Climate Action Fund, is
rolling out high power charging hubs across the country. These hubs will be capable of quickly
charging between two and eight vehicles simultaneously and will facilitate vehicles travelling longer
distances across Ireland’s National and Motorway routes.
In line with ESB Strategy, we are examining the role ESB could play in a hydrogen economy. This
could include the development of Hydrogen projects that are fully aligned with the “EU strategy on
energy sector integration” launched in 2020. This prioritises a more ‘circular’ energy system, with
energy efficiency at its core, greater direct electrification of end-use sectors like transport and
buildings and using a renewable fuel like hydrogen for end-use applications where direct
electrification is not feasible such as heavy goods transport, high temperature industrial heat and the
cement/ oil industries.
ESB Telecoms & Telecommunications Infrastructure
ESB Telecoms has grown from its original function of providing a communications system for ESB
to become one of Ireland’s leading independent telecommunications infrastructure providers with
over 400 locations nationwide. ESB Telecoms now provides network solutions for a wide variety of
mobile network operators, wireless broadband providers and public sector business activities. All
sites developed by ESB Telecoms are made available to third party mobile phone and wireless
broadband operators as points for co-location. Our open policy of sharing infrastructure limits the
overall number of telecoms structures appearing in urban and rural landscapes.
Our telecoms fibre network wrapped on our 110kV electricity network provides an extensive network
throughout Ireland with international connectivity to the UK. In addition, SIRO (a joint venture
between ESB and Vodafone) is bringing 100% fibre-to-the-building to 50 towns across Ireland
enabling speeds of 1 Gigabit per second. SIRO will continue to accelerate this roll-out in 2021.
2. PLANNING POLICY & THE DRAFT CDP
In reviewing the Draft CDP, ESB has a number of observations in relation to the key issues identified that
may set the framework for the future development of the County. ESB acknowledges that the process of
preparing a new CDP shall be informed by the hierarchy of planning policy in Ireland. Both the National
Planning Framework (NPF) and the Regional Spatial Economic Strategy (RSES) contain policies in relation
to Energy Infrastructure.
In addition, we welcome the recognition that the CDP will play an important role in influencing a reduction in
Green House Gas (GHG) Emissions by guiding the sustainable growth of the county. ESB is working
towards the delivery of Ireland’s target (part of the pledged EU target) of at least 40% reduction in domestic
GHG emissions by 2030 compared to 1990 levels.
The Draft National Energy and Climate Plan envisages a target of at least 55% renewable energy in
electricity by 2030. In 2019, the Minister of Communications, Climate Action and Environment committed to
raise the amount of electricity generated from renewable sources to 70% by 2030 with no generation from
peat and coal in the Climate Action Plan. This ambition is needed to honour the Paris Agreement. It
represents a significant change for the electricity industry and ESB is committed to doing its part in
supporting and delivering on the Government’s energy policy. We welcome the recognition in the Draft CDP
that it is a Strategic Objective (SO 4) of Louth County Council, to;
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 4“Transition to a low carbon and climate resilient County supporting energy efficiency and
reducing energy demand, through a combination of mitigation and adaptation responses to
climate change. This includes for increased usage of renewable energy through developing
indigenous energy resources, supporting the transition to a low carbon economy by 2050,
and ensuring flood risk management”
ESB supports a new CDP which will include policies and objectives to support the delivery of infrastructure
to meet future energy needs.
Electricity Transmission & Distribution
Both the NPF and the RSES contain promoting policies in relation to Energy Infrastructure and ESB
fully supports the reinforcement of those policies at a local level. Policy Objective EE 30, set out in
Chapter 5 – Economy and Employment, states;
“To promote the development of essential infrastructure and utilities that support
businesses in establishing a competitive and resilient stronghold at local, regional
and national level.”
The NPF and RSES for the Eastern & Midland Region supports the enhancement and upgrading of
existing infrastructure and networks and the safeguarding of strategic energy corridors from
encroachment by other developments that would compromise the delivery of energy networks. The
new County Development Plan 2021 – 2027 must continue to ensure that the long-term operational
requirements of existing utilities are protected.
The Draft CDP, deals with Energy Supply & Infrastructure under Section 10.10.1 and it supports
development of a secure and reliable transmission network, ensuring that Louth has the necessary
infrastructure to accommodate and promote economic growth, attract investment to the area and
facilitate the development of the County in line with the Core and Settlement Strategies. It also seeks
to support the safeguarding of strategic route corridors, where appropriate, and the development of
enhanced electricity networks to strengthen all-island energy infrastructure and interconnection
capacity. In this regard, we support the Draft Development Plan Objectives IU67 & IU68 as set out in
Chapter 10.
IU 67
“To support and facilitate the reinforcement and development of enhanced electricity
and gas supplies, and associated networks, to serve the existing and future needs
of the County and Region. This will include the delivery of the necessary integration
of transmission network requirements facilitating linkages of renewable energy
proposals to the electricity and gas transmission grid, in a sustainable and timely
manner, subject to appropriate environmental assessment and the planning
process.”
IU 68
“To support statutory and other providers of national grid infrastructure by protecting
strategic route corridors from encroachment by development that might compromise
the provision of energy networks.”
However, Policy Objectives IU 70 gives rise to concern as it restricts the consideration of all options
before the details and specific circumstances of individual projects have been considered and
therefore may prevent implementation of the optimum solution.
IU 70
“To require the under-grounding of electrical cables within new residential,
commercial or civic developments. Where existing, and proposed high voltage lines
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 5traverse new residential, commercial or civic developments, these should be re-
located under-ground where technically feasible”
It is recognised that concerns about visual, amenity, health and safety need to be mitigated through
the consultation process. The national planning framework of the NPF, RSES, Local Development
Plans and the Strategic Infrastructure Act provides the necessary framework for ensuring that all
necessary standards are met, and that extensive statutory and non-statutory consultation is an
intrinsic part of the planning process. This ensures that there is ongoing consultation with local
communities and local authorities regarding the construction of new networks.
The Government Policy Statement on the Strategic Importance of Transmission and Other Energy
Infrastructure (July 2012) emphasises the strategic and economic importance of investment in
networks and energy infrastructure. Under this policy the Government has mandated the State-
owned Networks Companies “to deliver the State’s network investment programmes in the most cost
efficient and timely way possible in the interests of all energy consumers who need the investment
and who also pay for it.”
Restrictive policies which outline the preferred option, as in the case above, in advance of the
required analysis and planning process are not consistent with the policies and objectives of the
Government which require “that these investment programmes are delivered in the most cost efficient
and timely way possible, on the basis of the best available knowledge and informed engagement on
the impacts and the costs of different engineering solutions.”
In addition, Government policy recognises that public acceptability is required for the delivery of key
networks projects and that to achieve public confidence project proposals must adhere to the highest
international standards of safety, health and environmental and visual impact, and technology choice.
The Government affirms that ESB Networks are obligated to adhere to all relevant guidelines and
standards and they act in the national interest, and on behalf of all electricity consumers.
Generation & Renewables
To achieve a transition to a low carbon, climate resilient and environmentally sustainable economy
and in line with the Government’s response to the Climate Change Crisis, ESB is committed to
leading the delivery of a low carbon energy sector. We are implementing programmes supporting the
Government strategies to reach Ireland’s 2030 reduced emissions targets and increasing renewables
in our power system from 30% to at least 55% with a broader range of technologies likely to be
deployed, e.g. offshore wind, solar, biomass.
ESB welcome the vision and ambition set out in Section 10.5.1 of the Draft CDP – Energy.
“A reliable, resilient and efficient energy system that caters for growth year-round
and across all sectors, will be required to underpin the future development of the
County. Louth requires world class energy infrastructure which is fit for purpose and,
in this regard, our native renewable energy sources need to be developed.”
As recognised in the Draft CDP, given its coastal location, Louth has a clear path to play in the
development of renewable energy and the provision of such alternative energy resources will be
considered on suitable sites throughout the county. In order to further this aim the development of a
Renewable Energy Strategy is an important objective. Therefore, ESB welcome the commitment set
out in Policy Objective IU47 which aims to;
“To produce a Renewable Energy Strategy for County Louth during the lifetime of
this Development Plan. This strategy shall have regard to ‘A Methodology for Local
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 6Authority Renewable Energy Strategies’, (SEAI) and shall be compliant with the
requirements of SEA & Habitats Directive.”
The development of a comprehensive Renewable Energy Strategy will provide an opportunity to
reinforce the supportive Policy Objectives in the Draft CDP in relation to renewable energy and ensure
full alignment with the objectives of the NPF, RSES and national guidelines. However, ESB wish to
make some comments in relation to the renewable technologies set out below.
Onshore Wind Energy
Based on SEAI analysis, February 2020 provided a record-breaking month with 56% of energy
demand met by wind energy, the highest monthly total since records began. In the 12 months
to end of January 2020, wind and other renewable sources, hydro, solar and biomass accounted
for 37% of demand. This is an encouraging trend, but further acceleration of deployment is
necessary to achieve the Government’s target for electricity of 70% from renewables by 2030.
Section 10.6 – Wind Energy recognises the significant contribution that wind energy can make
as a clean sustainable solution to energy requirements and its vital role in helping achieve
national targets in relation to fossil fuel reductions and consequently greenhouse gas emissions.
Map 10.1 in Chapter 10 Utilities provides details of the locations in the County suitable for wind
energy development. In addition, the Development Management Standards highlight that any
application for wind energy development shall be prepared in accordance with the requirements
of the Wind Energy Guidelines 2006 and any subsequent Guidelines. This reinforces Policy
Objective IU 51 that states;
“To encourage the development of wind energy, in accordance with
Government policy and have regard to the principles and planning guidance
set out in the Department of Housing, Planning and Local Government
publications relating to Wind Energy Development and the DCCAE Code of
Practice for Wind Energy Development in Ireland and any other relevant
guidance which may be issued in relation to sustainable energy provisions
during the course of the Plan.”
A review of the Wind Energy Development Guidelines 2006 has been underway since 2013. In
June 2017 a “preferred draft approach” was jointly announced between the Dept. of Housing,
Planning, Community & Local Government (DHPCLG) and the Department of Communications,
Climate Action and Environment (DCCAE). The recently published Draft Revised Wind Energy
Development Guidelines (2019) confirm the “preferred draft approach” which should inform the
planning authority policy for wind energy development. Therefore, it is appropriate that planning
policy and development management standards for sustainable wind energy developments are
updated where required to reflect the revised guidelines. In this regard we welcome the intention
of the Council to amend the wind chapter to consider changes of the new revised draft guidelines,
including amendments to development management standards.
Cross border co-operation in relation to the provision of all-island renewable energy is highlighted
in Policy Objective IU45, however, ESB suggest that this should extend to all neighbouring
counties. There is merit in assessing the County Development Plans and Wind Energy
Strategies of adjoining counties. It is noted that there is good consistency across County
Development Plan’s and the Wind Energy Strategies of some counties. However, there is scope
to improve on this consistency further in order to facilitate the development of windfarms across
county boundaries. Implementation of Regional Policy Objectives (RPO 10.19 - RPO 10.24) of
the RSES would help ensure consistency across the region. Unless this is achieved, a windfarm
development on one side of border may not have scale to compete in future Renewable
Electricity Support Scheme auctions and therefore may never get built – thereby reducing
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 7opportunity for both counties to benefit from jobs, rates and community benefit schemes
associated with the windfarm development.
Offshore Wind & Marine Renewables
Chapter 5 of the Draft CDP recognises the potential of the Blue Economy for County Louth and
the pivotal role that renewable energy can play. In Section 5.10 it states;
“Louth has a coastline of over 90 kilometres providing significant
opportunities for the support of a range of marine activities such as
aquaculture, defence, energy, fisheries, mining and aggregates, ports
harbours and shipping, telecommunications cables, tourism, safety at sea,
sport and recreation, and waste-water treatment and disposal.”
As highlighted, the emergence of opportunities to exploit offshore energy potential have
developed significantly in recent years and will continue to do so as technology advances in this
sector. ESB in partnership with Parkwind aims to develop Oriel and Clogherhead off-shore wind
farms in the coming years. Oriel Wind Farm planning application is at an advanced stage of
preparation and the development aims to deliver 330MW of renewable energy. In this context,
ESB wish to highlight our support for Policy Objectives IU55 & IU 56;
IU 55
“To support the development of off shore windfarm developments subject to
normal planning considerations, including in particular the impact on areas
of environmental or landscape sensitivity.”
IU 56
“To ensure that terrestrial developments along the coastline provide
adequate provision for connection to the national grid for off-shore wind
farms.”
We welcome the recognition under the above Policy Objectives in the Draft CDP that the Council
will support off-shore development and the development of land-based infrastructure for these
developments. In addition, we acknowledge that following the preparation of the Marine Spatial
Plan the Council will ensure that there is alignment and consistency between land use and
ocean-based planning. This will be important to ensure the delivery of Policy Objective IU65;
IU 65
“To support the development of wave and tidal energy in suitable waters off
the coast of County Louth subject to the protection of important marine
habitats and acceptable visual and environmental considerations.”
Solar
Photovoltaic (PV) systems which produce electricity directly from solar radiation are becoming
more widespread as their advantages become apparent and as costs fall. Given its coastal
location, County Louth has some of the most favourable photovoltaic solar electricity potential in
Ireland as the east coast gets significant levels of sunshine.
Solar projects will play a critical role in diversifying our renewable generation portfolio for the
period out to 2030. Ireland is in a great position to take advantage of the significant reduction in
the cost of solar energy over the past few years as the technology has advanced with the
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 8potential to provide a clean, diversified renewable electricity source for decades to come. Solar
energy is suited to Ireland’s climate and we expect to follow the trend of other European countries
and see increasing deployment of rooftop and grid scale solar energy. There is a strong
correlation between wind and changing weather systems. In times of low wind there are often
good solar conditions.
As highlighted in Section 10 of the Draft CDP, Louth’s coastal location coupled with a good solar
irradiation and significant grid network present opportunities to maximise energy generation by
solar means. In this regard, we welcome Objectives IU 57 & IU 58 and the support for associated
transmission & distribution infrastructure.
IU 57
“To support the development of solar energy infrastructure in the County
including commercial scale ground mounted solar PV “Solar Farms” subject
to environmental safeguards and the protection of natural and built heritage
features, biodiversity and views and prospects.”
IU 58
“To encourage and support the development of solar energy infrastructure
for on-site energy use, including solar PV, solar thermal and seasonal
storage technologies.”
Section 13.16.2 – Solar Energy in the Development Management Standards of the Draft CDP
highlights, in the absence of national guidance, the criteria that should be considered when
preparing an application for a solar farm.
ESB wish to highlight that currently Solar PV developments can take in excess of 5 years to
develop to construction phase. Securing a grid connection, relevant support tariff or corporate
power purchase agreement and securing project finance has introduced significant delays for
developers. Therefore, notwithstanding the provisions of Section 42 of the Planning &
Development Act 2000 (as amended), the Planning Authority should retain the option to grant
permission for a longer period, than the standard 5 years, if requested by the developer in
appropriate circumstances.
In addition, it should be noted that the lifetime of solar developments is extending with most
technologies now suitable for a minimum of 30 years operation. Investment decisions for projects
are being made on project lifetimes of up to 40 years. In this regard, ESB request that
permissions are granted with a lifetime up to a maximum of 40 years. Concerns regarding the
deterioration of the infrastructure can be addressed by the lodgement of a financial security in
the form of a bond and the requirement to provide a Decommissioning Plan, as specified. This
will ensure that the development is maintained until decommissioned and appropriately restored
to agricultural use.
Energy Storage
The Policy Objective as laid out in Section 10.7 of the Draft CDP, supports the development of
seasonal energy storage technologies in the County. Storage systems such as battery storage,
liquid air storage and synchronous condensers are some of the storage technologies being
explored that will be essential to smoothing out the natural variability that occurs in renewable
energy sources and to provide electricity at times of peak demand.
ESB wish to highlight, that Green Hydrogen, which is produced from renewable energy sources,
offers potential for large scale seasonal storage of variable renewable energy. This enables zero
carbon backup to the power system when intermittent renewables such as wind and solar are
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 9not available. Large scale Green Hydrogen production and storage could leverage the
continental scale of Ireland’s renewable energy potential to enhance Ireland’s energy security
and to make Ireland a net exporter of energy.
In addition to the Objective included in Section 10.7, we would welcome the inclusion of specific
policies supporting these new technologies.
Hybrid Renewables
Hybrid sites and hybrid units present an opportunity to provide more flexible plant with improved
capacity factors with potential for optimising use of existing infrastructure. To this end, Eirgrid
already allows an increase in the installed capacity of existing connections without increasing
the Maximum Export Capacity (MEC). By developing hybrid renewables plant consisting of wind,
solar and battery exporting from common point of connection, but at different times, the need for
transmission infrastructure associated with new generation is minimised and grid stability can be
improved on.
Additionally, repowering with hybrid renewables can grant a new lease of life to existing
windfarms and other generation sites. As recognised in the Draft CDP, County Louth is
exceptionally well served by the grid with cross border 275kV lines, existing 220kV transmission
lines providing a high capacity path for power to the east of Ireland. This is in addition to an
extensive 110kV and 38kV network. For these reasons, there is a strong argument for giving
hybrid renewables plant favourable consideration in suitable locations in County Louth.
Demand Management
Considering the potential of generation from offshore windfarms proposed for Louth and the
North South Interconnector bringing power from Northern Ireland via Louth 220kV Station, there
may be an excess of electricity supply relative to demand in County Louth. Examples of demand-
side management opportunities that could reduce the overall costs of energy and encourage
investment & jobs in County Louth;
• Encouraging companies with large energy demand to implement demand-management
systems to enable them to vary the timing of their electricity usage to meet their heat, lighting
and process requirements more efficiently. If the necessary supports from the Local Authority
were in place to assist and encourage firms to design and install demand-management
systems that meet their needs, it could become a contributory factor in choosing Dundalk or
Drogheda as a base for operations.
• Strengthening the fibre optic network around Dundalk or Drogheda appropriately, where
there may be opportunities to attract data-centres to connect to grid in Louth to avail of
excess electricity from offshore windfarms or from the North-South interconnector.
Telecommunications
A high quality and competitive telecommunications service is considered essential in order to
promote industrial and commercial development and to improve personal security, enhance social
inclusion and mobility. This view is reinforced in the Draft CDP, in Chapter 10, where it highlights,
under section 10.4.2.4 that;
“The Council recognises the importance of high-quality telecommunication
infrastructure as a prerequisite for a successful economy and accepts the critical
importance of a high-quality telecommunications service at national, regional and
local level.”
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 10Draft Development Plan Policy Objectives IU 36 – IU 42 set out the requirements for a proposal for
planning permission for telecoms infrastructure. ESB supports the continuance of these Objectives
and the view of Louth County Council to facilitate the provision of telecommunications services at
appropriate locations within the County;
“To ensure the orderly development of telecommunications throughout the County
in accordance with the requirements of the Telecommunications Antennae and
Support Structures, Guidelines for Planning Authorities, DECLG, 1996, except
where they conflict with Circular Letter Pl07/12 which shall take precedence, and
any subsequent revisions or expanded guidelines in this area.”
ESB’s telecoms infrastructure in the county continues to assist in delivering enhanced
communications networks through the provision of backhaul fibre and shared telecommunications
towers. The updated Guidelines and the development management standards set out in Section
13.16.3 facilitate the improved development of telecommunications infrastructure and promotion of
a policy of co-location. All ESB Telecoms Mast sites are open for co-location and duplication of
infrastructure is reduced as a result. ESB supports the Telecommunications policy that promotes co-
location.
ESB encourages policies consistent with the Department Circular to allow for the improved
development of telecommunications infrastructure, particularly broadband capability in the area. In
addition, we welcome the consideration of Telecommunications in Chapter 5, Section 5.10 – Marine
Opportunities Including Ports, promoting landside infrastructure to support international connectivity
for telecommunications cables.
Sustainable Transport & Electric Vehicles
With Ireland's natural advantages in terms of wind and other renewables a large proportion of the
power used by electric cars will be carbon free in the future. The Irish Government’s Climate Action
Plan 2019 has set stretching targets for EV adoption in Ireland in order to address energy demand
and reduce emissions from Transport including achieving:
• 840,000 passenger vehicles by 2030.
• 95,000 electric vans and trucks by 2030.
• Procuring 1,200 low-emissions buses for public transport in cities.
• Building the EV charging network to support the growth of EVs at the rate required and
develop our fast-charging infrastructure to stay ahead of demand.
The above targets demonstrate that EV’s (incl. plug-in hybrid electric vehicles PHEV’s) are central
to Government targets for zero carbon emissions transportation systems. The establishment of EV
infrastructure by ESB and the associated EV usage aligns with the key principles and benefits of
sustainability and the National Climate Change Strategy on reduction of emissions.
ESB welcome the support for Electric Vehicles as set in Chapter 7 of the Draft CDP – Movement,
where it states;
“Electric Vehicles (EV) include both Battery Electric Vehicles (BEV) and Plug-in
Hybrid Electric Vehicles (PHEV). They are low emission vehicles (LEVs) which use
low carbon technologies, emit low emissions and offer a more sustainable transport
solution. These clean and energy-efficient vehicles will have an important role in
reducing greenhouse gas emissions in the transport sector and improving air quality
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 11and reducing noise pollution in towns and villages. There are various charging units
for EV’s around the County. This Draft Plan promotes the further installation and
expansion of charging points for these vehicles.”
This is reinforced by Objectives MOV 6 & MOV 7 in the Movement Chapter and underpinned by
Section 13.14.9 of the Development Management Standards, which state;
“In all car-parking areas, provision shall be made for charging points for Electric
Vehicles. This shall include the necessary wiring and ducting. Pending the
publication of guidance on the minimum requirement of these spaces, an
assessment shall be made on a case-by case basis; however, applicants shall strive
to provide a minimum these charging points in 20% of the total spaces.”
ESB are of the view that the above objectives and standards will ensure that policy in this area is
consistent with National and Regional Policy in relation to the provision of electric vehicle
infrastructure. The above standards or similar have been implemented in the latest review of
development plans by planning authorities in Ireland. Promoting policies and objectives are
facilitating growth in charge point infrastructure, to become a comprehensive network of public and
domestic charge points with open systems and platforms accessible to all supply companies and all
types of electric cars.
As the use of electric vehicles continues to increase the Council may increase the
number of parking spaces to be equipped with fully functional charge points in either
of the above cases.
Other Sustainable Transport
Green renewable hydrogen enables the further electrification of transport, allowing the full
decarbonisation of the transport sector, as well as improved air quality as the technology replaces
diesel buses and diesel HGV across Ireland. ESB is currently part of a new, in-service, trial of a fuel
cell electric bus in the Dublin area. These buses are powered by hydrogen produced from renewable
electricity from ESB’s iconic Ardnacrusha power station. ESB has been actively engaging with
Hydrogen Mobility Ireland, a partnership of businesses from across many sectors, together with
public sector and academic stakeholders, with all-Island cooperation, joining together to deliver a
coordinated approach to the introduction of this cutting-edge technology to ensure that Ireland can
benefit from being an early starter in this solution to further decarbonise transport using renewable
energy.
3. CONCLUSION
Investment in infrastructure is crucial to the economic and social well-being of our country. Such investment
creates jobs, stimulates economic activity and provides modern, efficient facilities to provide the services
that people need including healthcare, education and community services amongst others. There is a
significant multiplier effect from investment in infrastructure which means that it stimulates growth in the local
economy. This investment in infrastructure is also necessary to support EU and national policy on Climate
Change adaptation and mitigation.
ESB, Ireland's leading electricity utility, is building a truly sustainable company by investing in smart
networks, renewable energy and modernising the generation portfolio. Sustainability, both within the
company and in the services, we provide, is integral to our corporate strategy. We are committed to reducing
carbon emissions and addressing long-term concerns over future fuel supplies. ESB is implementing energy
strategies that support the transition of Ireland to a low-carbon and ultimately post-carbon economy to
become a competitive, resilient and sustainable region. We request that due consideration is given to the
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 12issues raised in this submission, most particularly, that the final County Development Plan includes clear
policies in relation to:
• Ensuring that the long-term operational requirements of existing utilities are protected. The
importance of existing infrastructure and the associated Power Generation, Transmission and
Distribution operations are strategic and national in nature.
• ESB is concerned that policies that are too restrictive may prevent the development of the optimum
design for energy networks infrastructure where all the technical, environmental and economic
factors are fully considered. Restrictive policies, such as UI 70, which outline the preferred option in
advance of the required analysis and planning process are not consistent with the policies and
objectives of the Government which require “that these investment programmes are delivered in the
most cost efficient and timely way possible, on the basis of the best available knowledge and
informed engagement on the impacts and the costs of different engineering solutions.”
• The final Plan should maintain the planning policies which protect the county’s future capacity for the
development of energy infrastructure whilst encouraging the sustainable development of renewable
energy resources, including energy storage systems. This will enable ESB to develop and maintain
a safe, secure, reliable, economical and efficient electricity Generation, Transmission and
Distribution System with a view to ensuring that all reasonable demands for electricity are met having
due regard for the environment.
• For the development of wind projects, the recently published Draft Revised Wind Energy
Development Guidelines (2019) should inform the planning authority policy.
• It is appropriate that permissions for Solar PV are granted with a lifetime up to a maximum of 40
years which reflects the operational life and financial modelling for current solar technologies.
Concerns regarding the deterioration of the infrastructure can be addressed by the lodgement of a
financial security in the form of a bond and the requirement to provide a Decommissioning Plan, as
specified. This will ensure that the development is maintained until decommissioned and
appropriately restored to agricultural use.
• Facilitating expansion and improvement in telecommunications infrastructure and to help position
the county to attract intellectual & physical capital and to act as a mechanism to improve virtual
connectivity.
• Promoting, encouraging and facilitating the use of sustainable modes and patterns of transport,
including electric vehicles, with appropriate Parking Standards that will set minimum levels of parking
provision for EVs.
If we can be of any further assistance, or if you wish to clarify any of the points raised, please do not
hesitate in contacting the undersigned.
Yours sincerely,
Gerard Crowley | Planning and Asset Manager | Group Property and Security, 42 Merrion Sq., Dublin 2.
| T: +353 1 702 7163 / +353 87 237 4107 | www.esb.ie
23/12/2020 Louth County Council Draft Development Plan 2021 - 2027 13You can also read
